VOLUME 12  INTERNATIONAL AVIATION

CHAPTER 4  PART 129 OPERATIONS

Section 10  Ramp Inspections for Part 129 Foreign Air Carriers

Source Basis:

•    Section 129.5, Operations Specifications.

•    Section 129.7, Application, Issuance, or Denial of Operations Specifications.

•    Section 129.9, Contents of Operations Specifications.

•    Section 129.11, Amendment, Suspension and Termination of Operations Specifications.

•    Section 129.13, Airworthiness and Registration Certificates.

•    Section 129.14, Maintenance Program and Minimum Equipment List Requirements for U.S.-Registered Aircraft.

•    Section 129.17, Aircraft Communication and Navigation Equipment for Operations Under IFR or Over the Top.

•    Section 129.18, Collision Avoidance System.

•    Section 129.20, Digital Flight Data Recorders.

•    Section 129.24, Cockpit Voice Recorders.

•    Section 129.25, Airplane Security.

•    Section 129.28, Flightdeck Security.

•    Administrative.

10.1    GENERAL.

10.1.1    Purpose. This section establishes the Federal Aviation Administration (FAA) Flight Standards Service (FS) policy and requirements for conducting ramp inspection within the United States or its territories on Title 14 of the Code of Federal Regulations (14 CFR) part 129 foreign air carriers.

10.1.2    Scope. This section is applicable to all FAA FS office personnel who manage and conduct ramp inspections on part 129 foreign air carriers.

10.1.3    Safety Assurance System (SAS) Activity Recording (AR) Codes.

a)    Operations: 1622.

b)    Maintenance: 3627.

c)    Avionics: 5627.

10.1.4    Regulatory References. All regulatory references in this section are found in 14 CFR unless otherwise indicated.

10.2    DEFINITIONS. See Volume 12, Chapter 1, Section 1, Definitions, Abbreviations, and Acronyms, for information associated with this section.

Note:  The International Program Division (AFS-50) international website may be accessed through the following link: https://my.faa.gov/org/linebusiness/avs/offices/afx/divisions/afs/afs50.html.

10.3    OBJECTIVES OF RAMP INSPECTIONS. The primary objectives of a ramp inspection are to provide aviation safety inspectors (ASI) with the opportunity to evaluate whether a foreign air carrier’s or foreign person’s operations and aircraft meet International Civil Aviation Organization (ICAO) Standards and are capable of safe operations when operating within U.S. airspace.

a)    When a foreign air carrier applies for operations into the United States, they are granted the authority to operate based on the fact they are operating within the ICAO Standards.

Note:  See Volume 12, Chapter 1, Section 3 for information and applicable references on ICAO Standards and Recommended Practices (SARPs).

b)    The ramp inspection provides the FAA with an opportunity to evaluate if the air carrier is meeting those standards as allowed in the part 129 operations specifications (OpSpecs) issued to the foreign operator or air carrier.

10.3.1    ASI Training. It is important that ASIs become familiar with the type of aircraft that they are inspecting before performing the inspection. For additional details, see Volume 12, Chapter 4, Sections 11 and 12.

10.3.2    Personnel Needed for Inspection.

a)    ASIs do not have to give part 129 foreign air carriers or foreign persons advance notice of a ramp inspection. However, the inspection activities must be timed so that they do not delay or interfere with passenger boarding or deplaning, or impede aircraft service or catering. The captain, the captain’s representative, or an appropriate airline representative should also be present.

1)    The FAA office with oversight authority of the airports located with in their geographic area has the responsibility for the required ramp inspections.

2)    Assign and conduct geographic inspections in accordance with FAA Order 1800.56, National Flight Standards Work Program Guidelines.

3)    International Field Offices (IFO) should not send ASIs to conduct inspections, surveillance, etc., in support of other FAA offices that would require official travel unless complete justification is provided to, and approved by, the International Field Office Management Branch (AFS-54).

b)    The FAA FS office with geographic authority over the airport where the air carrier has operations should complete all Required Surveillance Work Activities (R-item).

c)    If an ASI conducting the ramp inspection finds discrepancies with the environmental record, he or she must report those discrepancies to the responsible Flight Standards District Office (FSDO), certificate management office (CMO), or IFO.

10.3.3    Environmental Files.

Note:  Refer to Order 1800.56 for more information on environmental files.

a)    Responsibility for Maintenance of Environmental Files. The IFO is responsible for the creation and maintenance of the environmental file for the scheduled foreign air carriers to whom they issue part 129 OpSpec A001. Maintenance, updates, and local validations to environmental files are the responsibility of the FS office (FSDO/CMO) located in the geographic area.

b)    Principal Inspector (PI) and FS Office Environmental Files. The responsible IFO must enter the responsible Flight Standards office in the environmental file that has the responsibility to conduct the required ramp inspections at the geographic airport.

1)    The IFO will communicate with the responsible Flight Standards office to notify them of the development or revision of an environmental file. The assigned ASIs listed in the environmental file will be assigned by the responsible Flight Standards office that will be conducting the ramp inspections for the geographic airport.

2)    The responsible IFO that issues part 129 OpSpecs must not create any environmental files for a foreign air carrier or foreign person that operates U.S.-registered aircraft in common carriage solely outside the United States.

10.3.4    Coordination.

a)    The FSDO/CMO with responsibility of the airports located within their area may need to coordinate with the IFO holding OpSpecs responsibility. In addition, the IFO with OpSpecs responsibility should receive notification when an ASI finds discrepancies.

b)    ASIs may coordinate with U.S. Customs and Border Protection (CBP) for foreign air carrier activity. Often, the ASI may not be able to access the aircraft until it has cleared CBP.

1)    ASIs are encouraged to cooperate with the CBP officials and follow their local policies when accessing the aircraft.

2)    ASIs should contact CBP in advance of the aircraft landing, and should therefore be able to receive information on the foreign air carriers that are operating into the United States.

10.3.5    Use of FAA ASI Credentials to Access Aircraft and Secure Areas of U.S. Airports. Proper use of identification credentials, correct checkpoint procedures, and resolution of misunderstandings with airlines and other government agencies are crucial for the creation of an environment where ASIs can conduct effective inspections and surveillance. Both FS and the Transportation Security Administration (TSA) have reaffirmed the necessity of ASI access to Security Identification Display Areas (SIDA) and Air Operations Areas (AOA). However, because of the TSA’s enhanced screening process and other airport security measures, ASIs must undergo extra steps when entering a SIDA.

Note 1:  FAA Order 8000.38, Aviation Safety Inspector Credentials Program, provides guidance and policy for the use of FAA Form 110A, Aviation Safety Inspector’s Credential. ASIs should refer to this order for specific guidance and policy on access to aircraft and secure areas of U.S. airports.

Note 2:  According to part 153, “Airports, aircraft operators, aircraft owners, airport tenants, and air agencies must grant Aviation Safety Inspectors bearing FAA Form 110A free and uninterrupted access to public-use airports and facilities, including AOAs, SIDAs, and other secured and restricted areas.”

10.4    INITIATION AND PLANNING.

10.4.1    Planning. When planning a work program, each ASI must review Order 1800.56 to determine the requirements for each assigned foreign air carrier or operator. The National Flight Standards Work Program Guidelines (NPG) require:

a)    Ramp inspections on each scheduled passenger and/or cargo part 129 foreign air carrier, and

b)    Ramp inspections on each nonscheduled foreign operator utilizing aircraft type certificated (TC) for 10 or more seats that operates within the region (environmental).

1)    The nonscheduled foreign operator must notify the responsible IFO of the arrival location and date before the flight (refer to OpSpec A001). The responsible IFO will notify the responsible Flight Standards office of the flight (refer to Order 1800.56).

2)    If the foreign operator does not notify the IFO, the ASI should work closely with the local CBP office that has oversight of the airport of entry to determine which nonscheduled foreign operators are operating into the area.

10.4.2    Surveillance. The NPGs also include requirements for the Heightened Surveillance List (HSL). This list is posted quarterly by AFS-50. National, divisional, or other FS office special requirements initiate additional inspections.

Note:  See Volume 12, Chapter 4, Section 13 for more information on the HSL.

10.4.3    U.S.‑Registered Aircraft. Foreign air carriers operating U.S.‑registered aircraft must meet all requirements of part 129, § 129.14. The ASI may need to coordinate with the responsible IFO if there are questions regarding the maintenance program or the minimum equipment list (MEL).

10.4.4    Scheduling the Inspection. When planning the ramp inspection, the ASI should plan to be at the aircraft after the passengers have departed the aircraft and before reloading.

10.5    MAINTENANCE RECORDS.

10.5.1    ICAO Requirements. ICAO Annex 6, Part I, International Commercial Air
Transport—Aeroplanes, governs maintenance records requirements.

a)    The maintenance program under part 129 should include those maintenance record requirements.

b)    The maintenance records requirements of ICAO Annex 6, Part I, 8.4.1 governs the part 129 records requirements of foreign air carriers and foreign persons.

10.5.2    Title 14 CFR Requirements for U.S.-Registered Aircraft. To meet the requirements of part 43 and § 129.14, the operator must make maintenance logbook entries and corrective actions in the English language.

10.6    RAMP INSPECTION JOB AID AND INSPECTION AREAS. Figure 4-10A, Foreign Carrier Ramp Inspection Job Aid, is completed by any ASI regardless of primary specialty. There are two primary inspection areas that an ASI can observe and evaluate during a part 129 ramp inspection. These inspection areas are:

a)    Air carrier operations (A); and

b)    Air carrier airworthiness (F).

10.7    GENERAL RAMP INSPECTION PRACTICES AND PROCEDURES.

10.7.1    Time and Location of Inspections. ASIs may conduct ramp inspections before a particular flight, at en route stops, or at the termination of a flight. They may conduct a ramp inspection any time an aircraft is at a gate or a fixed ramp location, provided the flightcrew or station personnel are present.

10.7.2    Inspection Conduct. ASIs do not have to give foreign operators advance notice that they will be conducting a ramp inspection. ASIs must, however, conduct inspections in a manner that does not unnecessarily delay crewmembers and/or ground personnel in the performance of their duties. ASIs should observe the following areas of conduct during ramp inspection activities:

a)    ASIs should not interrupt crew or ground personnel when they are performing a particular phase of their duties.

b)    When inspection activities require ASIs to interact directly with the crew or ground personnel, ASIs should perform the activities at a time that does not interfere with their duties.

c)    The ASI must time inspection activities so that they do not delay or interfere with passenger enplaning or deplaning.

d)    Inspection activities should not adversely impede aircraft servicing or catering.

10.7.3    Job Aid. ASIs must refer to the job aid (Figure 4-10A) when conducting ramp inspections. The job aid contains a listing of items that the ASI observes and evaluates during the inspection. The job aid also includes applicable SAS AR comment codes to facilitate the writing of the inspection report. ASIs should use the job aid to help describe how the inspection was limited in scope and to make notes during the inspection that they can later transcribe into SAS AR.

10.8    SPECIFIC RAMP INSPECTION PRACTICES AND PROCEDURES.

10.8.1    Crewmember Inspection Area. When an ASI makes direct contact with a flight or cabin crewmember:

a)    The ASI should provide an official and courteous introduction, offer appropriate identification for the crewmember to inspect, and inform the crewmember that a ramp inspection will be conducted.

b)    If the direct contact is with a flightcrew member, the ASI should request to see the crewmember’s airman and medical certificates. The ASI should review the certificates to see that they meet the appropriate requirements for both the duty position and the aircraft for the scheduled or recently terminated flight.

Note:  Beware of those situations that require additional action regarding the crew certificates under Article 83 bis (see Volume 12, Chapter 3, Section 5).

c)    ASIs should also request to examine the crewmember’s professional equipment. Crewmember professional equipment includes any equipment that crewmembers are required to have, according to regulations or operator policies, either on their person or available during the flight (e.g., aeronautical charts, appropriate operator manuals, and operable flashlights). ASIs should determine whether the charts and manuals carried by crewmembers are current.

10.8.2    Aircraft Inspection Area. Ramp inspections must include at least an examination of the aircraft’s registration, airworthiness certificate, and maintenance logbook. ASIs should plan their ramp inspections so that they conduct any inspection of the aircraft’s interior equipment and furnishings either before passengers enplane or after they deplane.

10.9    PERFORMING THE RAMP INSPECTION.

10.9.1    Discrepancies. ASIs must immediately bring any discrepancies noted to the attention of appropriate personnel to allow the operator the opportunity to take corrective action without interrupting the flight schedule. Safety-critical findings should be presented to the flightcrew or station manager as soon as practical. ASIs should also notify the IFO responsible for OpSpecs with a list of any discrepancies found.

10.9.2    Non‑Part 129 Operations. ASIs may encounter foreign‑registered aircraft that are not part 129 operations, but are operating under the provisions of part 375.

a)    The FAA office conducting the ramp inspection on an aircraft operating under part 375 will enter the following ramp inspection information into SAS AR:

1)    In the “National Use” field, select “375”;

2)    In the “14 CFR” field, enter “375”; and

3)    In the “Non-Cert.” field, enter the operator’s name.

i.    Include the operator name listed on the operator’s Air Operator Certificate (AOC) if the operator holds an AOC; or

ii.    If there is no AOC, include the operator’s name listed on the Department of Transportation (DOT) authorization.

b)    Refer to the SAS Resource Guide (SRG) for information to record the complete registration number if unable to record it in the aircraft registration field.

10.10    PREREQUISITES AND COORDINATION REQUIREMENTS.

10.10.1    Prerequisites:

a)    Experience working with similar type aircraft;

b)    Knowledge of ICAO Annexes 1, 6, 7, and 8;

c)    Completion of web-based training course number 27100142, How to Conduct a 14 CFR Part 129 Ramp Inspection; and

d)    Completion of all required on-the-job training (OJT) based on employee’s assignment.

10.10.2    Coordination.

a)    This task may require coordination between Maintenance, Avionics, and Operations ASIs.

b)    The inspector conducting the inspection may need to coordinate with the IFO with OpSpecs responsibility.

10.11    REFERENCES, FORMS, AND JOB AIDS.

10.11.1    References (current editions):

•    Title 14 CFR Parts 21, 43, 91, and 129.

•    ICAO SARPs contained in:

–    Annex 1, Personnel Licensing;

–    Annex 6, Operation of Aircraft;

–    Annex 7, Aircraft Nationality and Registration Marks; and

–    Annex 8, Airworthiness of Aircraft.

•    ICAO Doc 8335, Manual of Procedures for Operations Inspection, Certification, and Continued Surveillance.

10.11.2    Forms. FAA Form 110A, Aviation Safety Inspector’s Credential.

10.11.3    Job Aids:

•    Figure 4-10A, Foreign Carrier Ramp Inspection Job Aid.

•    Air Transportation Job Task Analysis (AT JTA) 2.2.5 (AW), Conduct a Ramp Inspection of a 14 CFR Part 129 Foreign‑Registered Aircraft.

•    AT JTA 2.3.58 (AW), Monitor a Maintenance Program for U.S.‑Registered Aircraft Operated by a Foreign Operator.

10.12    PROCEDURES.

10.12.1    Begin the Inspection. Begin the ramp inspection in accordance with the responsible Flight Standards office’s work program or other directives.

10.12.2    Prepare for the Inspection.

a)    Coordinate with all ASIs, select the flight to be inspected, and determine the ground time needed.

b)    Determine recent problem areas identified for that type of aircraft or the operator, if any.

c)    Determine if recent ICAO changes affect the inspection.

d)    Verify if the air carrier is currently listed on the HSL. Refer to the AFS-50 website for this information.

Note:  Surveillance of “OFFHOUR” operators may require management approval.

10.12.3    Introduction to Company Personnel. The ASIs should introduce themselves and describe the purpose and scope of the inspection. The flightcrew may not always be available or present when performing the ramp inspection. An operator’s representative should be present during inspections inside the aircraft.

10.12.4    Analyze Findings. Analyze each finding to determine what action, if any, should be taken.

10.12.5    Debrief the Flightcrew, Station Personnel, and Operator. At the completion of the inspection, inform the flightcrew, if present, of any findings. For a safety-of-flight discrepancy, the ASI must immediately inform the flightcrew or station personnel and the operator. For internal FAA coordination of safety-of-flight discrepancies, see paragraph 10.12.6 below.

10.12.6    Grounding of Foreign Operator Aircraft. The ASI does not have the regulatory authority to ground foreign operators’ aircraft. If the findings discovered during the inspection put the safety of flight into question, then the flightcrew, station personnel, and operator must be immediately notified.

a)    The ASI will immediately notify their supervisor, who will immediately notify their Regional Operations Center (ROC).

b)    The ASI will also immediately notify the IFO/PI with OpSpecs responsibility and provide them with a list of the findings.

1)    The IFO/PI with OpSpecs responsibility will notify the air carrier, and the IFO management will notify the Civil Aviation Authority (CAA) of the State of the Operator.

2)    The IFO/PI with OpSpecs responsibility will take the appropriate action after notifying and consulting with their managers, AFS-54, and FAA headquarters general counsel.

c)    ASIs and PIs should carefully review the standards of applicable ICAO Annexes when making a determination if a foreign aircraft is found to not meet ICAO Standards.

10.13    TASK OUTCOMES.

10.13.1    Complete the SAS AR Record.

a)    The data reporting requirements for completing a part 129 aircraft ramp inspection using surveillance activity codes 1622, 3627, and 5627 have been revised. Section IV of the job aid (Figure 4-10A) indicates each area that the ASI should examine in the performance of 1622, 3627, and 5627 inspections.

1)    An asterisk (*) designates the minimum inspection items that the ASI should complete during the inspection.

2)    For each discrepancy or finding, enter the appropriate primary area and keyword on the job aid.

3)    If unable to enter all of the digits of a pilot certification number in the “Airman Certificate Number” block of the SAS AR record, then enter the complete certificate number in the comment section of the SAS AR record. Use keyword “F645I” and add a comment that the full registration number does not fit. ASIs do not need to enter asterisk items that are satisfactory into the record.

4)    If a positive comment is necessary in a particular area for clarification, enter it using the appropriate primary area and keyword shown on the SAS AR record, using opinion code “I.”

5)    If the ASI cannot evaluate a minimum inspection keyword, then the ASI must enter opinion code “I” into the “Assessment” block and a brief explanation of why it was not evaluated into the “Comment” field.

Note:  Either Operations or Airworthiness ASIs can complete “A” for operations items and “F” for airworthiness items. ASIs should not duplicate work or record duplicate entries.

b)    For all findings requiring additional research, the ASI should contact the IFO responsible for OpSpec oversight and consult with the PI to resolve or clarify the findings. When the ASI has a finding with an opinion value of “U,” the ASI must contact the IFO/PI in charge of managing the OpSpecs, who will report the information to the CAA of the State of the Operator.

c)    Debrief the flightcrew or station manager of all findings noted.

d)    ASIs should enter all ramp inspections into SAS AR.

e)    If the HSL requirement generates the inspection, select “HSL” in the “National Use” field in Section III of the SAS AR record.

f)    Record the location of the inspection into the point of departure block (“Loc/Dep”) on the SAS AR record using the four‑letter ICAO identifier code for the airport. Do not use the point of arrival block (“Loc/Arv”) for any reason. The location of the ramp inspection is the only information required.

g)    ASIs must address and record all items with an asterisk in the job aid into the SA AR record if he or she finds a discrepancy.

h)    It is necessary to backspace to remove the “N” to enter a foreign‑registered aircraft. Enter the aircraft number as it appears on the registration certificate. If the registration number is longer than six characters, do the following:

1)    Omit characters, beginning with the last character, until what is left fits in the field (ensuring that the country code is captured and preserved, noting that some country codes have as many as three characters); and

2)    Put the entire registration number in the “Comment” field using “H999I” as the comment code.

10.13.2    Task Completion. Completion of this task may result in the following:

a)    Appropriate enforcement action when the analyses of the findings disclose safety issues contrary to the ICAO Standards. Enforcement action is the responsibility of the office/ASI that discovered the violation. However, the office/ASI should coordinate all findings and violations with the IFO responsible for OpSpecs.

b)    The station manager or flightcrew will be debriefed on all findings.

c)    Notify the FS office that has OpSpecs responsibility with a copy of all discrepancies/findings.

10.14    FUTURE ACTIVITIES. Based on inspection findings, determine if closer surveillance, additional enforcement, other job tasks, and/or additional coordination between the IFO with OpSpecs responsibility, State of the Operator of the aircraft, and geographic units are required to regain compliance.

Figure 4-10A.  Foreign Carrier Ramp Inspection Job Aid

Note:  This guidance is in accordance with ICAO Doc 8335, Manual of Procedures for Operations Inspection, Certification, and Continued Surveillance, Section 5.4.